ML20044F704
| ML20044F704 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/24/1993 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-93076, NUDOCS 9305280426 | |
| Download: ML20044F704 (8) | |
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P.O. Box 300 Od seabrook. "" 03874 Telephone (603)474-9521 Facsimile (603)474-2987
' Energy Service Corporation Ted C. Feigenbaum Senior Vice President and Chief NuclearOfficer NYN-93076 May 24,1993 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Document Control Desk
References:
(a)
Facility Operating License No. NPF-86, Docket No. 50-443 (b)
USNRC Letter dated April 23, 1993, " Inspection Report No.
50-443/93-05,* A. R. Blough to T. C. Feigenbaum (c)
North Atlantic Letter NYN-92125 dated September 25,1992, "Licen se e Event Report (LER) 92-013-00: Tornado Design of Plant Doors," T.
C. Feigenbaum to USNRC (d)
North Atlantic Letter NYN-92161 dated November 20,1992, " Lice nsee Event Report (LER) 92-013-01: Tornado Design of Plant Doors," T.
C. Feigenbaum to USNRC (c)
North Atlantic Letter NYN-92146 dated October 23,1992, ' Tornado Design of Flant Doors," T. C. Feigenbaum to USNRC
Subject:
Reply to a Notice of Violation Gentlemen:
In accordance with the requirements of the Notice of Violation contained in Reference (b), the North Atlantic Energy Service Corporation (North Atlantic) response to the cited violation is provided as Enclosure 1.
Should you have any questions concerning this response, please contact Mr. James M.
Feschel, Regulatory Compliance Manager, at (603) 474-9521, extension 3772.
Very truly yours, Ted C. Feigenbaum TCF:JES/jes/t ad Enclosure 250077.
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- 9305280426 930524 7 a member of the Northeast Utilities system
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- 4 United States Nuclear Regulatory Commission May 24,:1993 Attention:
Document Control Desk Page two ce; Mr. Thomas T. Martia Regional Administrator.
U..S. Nuclear Regulatory Commission
- Region 1 475 Allendale Road King of Prussia, PA ' 19406 Mr. Albert W. De Agazio, Sr. Project Manager Project Directorate I-4 Division of Reactor Projects U.S. Nuclear Regulatory Commission -
Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident inspector P.O. Box 1149 Seabrook, Nil 03874
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l North ~ Atlantic May 24,1993 ENCLOSURE I TO NYN-93076 l-i 1
b
HEPLY TO A NOTICE OF VIOLATION f
In a letter dated April 23,1993 [ Reference (b)], the NRC transmitted to North Atlantic Energy Service Corporation (North Atlan:ic) a Notice of Violation for approving a change to the design basis tornado described in Updated Final Safety Analysis Report (UFSAR) without first cornpleting the requisite safety evaluation pursuant to 10 CFR 50.59, and without updating the UFSAR. In accord:.nce witu the instructions provided in the. Notice of Violation, the North Atlantic response to this violation is provided below.
A.
Violation The Code of Federal Regulations 10 CFR 50.59 requires that a safety evaluation oc written pr'ior to changing the facility as described in the Updated Final Safety Analysis Report.
Contrary to the above, on June 26,1991 engineers failed to perform a written safety evaluation prior to changing the design basis tornado described in section 3.2.1.2(b)2
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of the Updated Final Safety Analysis report.
Thir. is a Severity Level IV violation (Supplement I).
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B.
Reason for the Violation i
As stated above, and as described in the letter transmitting this Notice of Violation,- there are three components to this violation that must be specifically addressed':
1.
Why a safety evaluation was not performed in a timely manner; 2.
Why the UFSAR was not updated; and, 3.
Why this nonconforming condition was not immediately reported to the NRC.
North Atlantic does not contest any portion of this violation. The specific reasons for this violation are described below.
As stated in Reference (e), North Atlantic originally identified a concern with the design of tornado barriers at Seabrook Station in late 1990 while developing a consolidated design basis document for plant barriers and while consolidating associated plant drawings. During ihis review, the Manager of Engineering adopted a site specific tornado as the design b. sis.
110weve r, at that time, Engineering management did not formally document a safety evaluation pursuant to 10 CFR 50.59 prior to adopting the new design basis. This was due, in part, to the Manager of Engineering's confidence that an unreviewed safety question and operability concerns did not exist as a result of the acceptance of the site specific tornado a
design basis. This confidence was founded on the informal evaluations that were performed l
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'A related issue pertaining to why seven nonconforming tornado doors were not included
-in the United Engincess and Constructors (UE & C) door specification as tornado barrier doors, was addressed in.both References (c) and (d).
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by the Engineering Department, utilizing existing industry guidance.
Based on this confidence, the Manager of Engineering determined that it was appropriate to perform the requisite UFSAR change and its associated safety evaluation upon final completion of the design basis document. Ilowever, completion _of the design basis document was not timely.
3 A factor contributing to the failure to formally document a safety evaluation, and in turn, the root cause for failing to update the UFSAR and to report this issue to the NRC, was the.
failure to implement the North Atlantic Corrective Action Program. Specifically, if the _
Corrective Action Program had been utilized, a Station information Report (SIR) would have been initiated. The SIR requires a detailed evaluation, determination of the root cause, and initiation of corrective actions to prevent recurrence. The SIR is reviewed by the Station Operation Review Committee (SORC). North Atlantic is confident that if this process was utilized, it would have prompted a safety evaluation to be performed. As a minimum, since
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a likely corrective action would have been to revise the UFSAR to incorporate the site specific tornado design basis, a safety evaluation would have been required to accompany
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the proposed UFSAR change.
All SIRS are also reviewed for reportability by the Regulatory Compliance Department. A reportability determination is documented and reviewed by the SORC. North Atlantic is confident that if the Regulatory Compliance Department review had been conducted as part of the SIR process, that this nonconformance would have been reported to the NRC. North Atlantic recognizes that while SIRS can be utilized for any significant events or potentially i
reportable issues, they are typically utilized for operational events.
This may have contributed to the lack of recognition that this issue warranted the initiation of an SIR.
A factor contributing to the failure to implement the aforementioned Corrective Action l
Program was an inadequate internal Engineering Department corrective action screening.
procedure.
At the time the tornado door issue was first identified, the Engineering.
.I Department had an internal screening process in place'via Engineering Procedare 34022,'
" Engineering Self Assessment Reports." While this procedure provided a means to document problems, assign resources to analyze the condition, and identify corrective actions to prevent recurrence, it did not adequately address operability and reportability, and it _did '
not adequately interface with the North Atlantic Corrective Action. Program.
These procedural inadequacies are highlighted by the fact that on December 12, 1990, an Engineering Self Assessment Report (ESAR# 90-004) was initiated for the tornado door -
i issue. This ESAR was not resolved in a timely manner. The Engineering corrective action screening procedure suffered from less than aggressive implementation, and-a lack of consistent utilization.
B.
Corrective Actions That Have Been Taken and the Results Achieved 1
t' The following corrective actions have been taken:
i 1.
North Atlantic reported this condition via a one hour verbal notification pursuant to'.
10 CFR 50.72(b)(1)(ii)(B) on August 27,1992.
2.
North Atlantic followed up the one hour notification with a Licensee Event Report (LER 92-013-0G)- [ Reference (c)), on September 25, 1992 pursuant to 10. CFR 50.73(a)(2)(ii)(B).
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North Atlantic supplemented this Licensee Event Report with LER 92-013 [ Reference (d)], on November 20,1992.
4 Plant Barriers have been consolidated into a single design basis document. Included in this document is a list of the barrier drawings that clearly identify the barriers which must maintain their integrity against air, water, pressure, weather, fire, or a combination thereof. Responsibility for the these barriers has been' clearly assigned.-
5.
North Atlantic completed a comprehensive reevaluation of plant design features relative to tornado design criteria. This reevaluation verified that the existing plant design, with the exception of the six doors, met the tornado design criteria specified in the UFSAR prior to its revision. These doors have been verified to be capable of withstanding the worst case site specific tornado, or the affected plant areas were verified to be capable of withstanding the corresponding depressurization.
6.
North Atlantic confirmed the tornado barrier envelope by a thorough inspection of the existing plant barrier drawings with subsequent confirmation by plant walkdowns.
7.
North Atlantic revised the UFSAR to include the site specific tornado design basis.
8.
Engineering Procedure 30070, " Engineering Self Assessment Reports" (formerly Procedure 34022), has been revised ta clarify responsibilities, reviews, and applicability of the procedure.
The revised procedure provides a method for scporting discrepancies and nonconformr.nces, and assures that timely evaluation, and.
corrective and follow-up actions are taken. The vehicle utilized by this procedure to document issues, or potential issues, is the Engineering Self Assessment ' Report (ESAR). The ESAR is a method by which potentialissues are screened for inclusion -
into corrective action documents, such as the Station Information Report (SIR), or the Operational Informational Report (OIR).
l Procedure 30070 allows for an ESAR to be initiated for any concerns, even those that appear to be below the threshold requirements for inclusion in the North Atlantic Corrective Action Program. Irrespective of this, an ESAR need not be utilized if the inue clearly falls into the jurisdiction of the Corrective Action Frogram As stated in Procedure 30070, examples of issues that may initiate an ESAR include:
Discovery of an as built condition that deviates or appears to deviate from the design basis of the relant as identified in the UFSAR.
Determination that there is a disagreement, or possible disagreemert, between different sections of the UFSAR or other documents that define the design basis of the plant.
A design change that fails to perform its intended function after the design change is operable.
Discovery of errors in approved engineering documents that are not addressed or capable of being resolved by other engineering processes.
Determination that an assumption in a calculation is not appropriate.
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a Determination that an engineering procedure is incorrect, provides conflicting <
requirements to other procedures, or provides inadequate direction.
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Engineering Procedure.30070 has also 1 een revised to include a review by the Regulatory Compliance Department if questions arise regarding reportability or j
applicability to corrective action documents.
9.
The Engineering Department has conducted training 'sessit is for appropriate-departmeat personnel (e.g., engineers, designers, managers) on the revised Procedure 30070.
This training explained the use of Procedure 30070, and stressed its importance for promptly identifying all engineering discrepancies to appropriate Engineering and Licensing management to ensure adequate corrective actions are q
taken. This trainiag also addressed the threshold and applicability for utilizing an l
ESAR, and how this process related to the. North Atlantic Corrective Action Program.
Additionally, this training reviewed the tornado door issue and discussed the reportability and the need to perform 10 CFR 50.59 cvaluations. It should be noted that this training will be conducted in the near future for any individuals that were.
i unable to attend the previous training sessions, j
i The ESAR process has been subsequently utilized on fourteen separate occasions.
This increase in utilization attests to the acceptance of the process and the cffectiveness of the training.
'1 10.
.As part of incorporating guidance from Generic. Letter 91-18, North Atlantic previously revised the Station Operating Experience Manual (SSOE) to explicitly l
clarify the applicability of an SIR for nonconforming or degraded conditions. This
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ensures that an SIR will be initiated for situations such as:
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A failure of a system, structure or component to conform to one of more applicable codes, standards, or commitments specified in the UFSAR; l
q As-built or a -modified systems, structures or components that do not meet -
UFSAR design requirements-Operating experience or engineering reviews that demonstrate a design j
inadequacy in 'a system, structure or component; a
Documentation required to verify that systems, structures or components conform to NRC requirements is deficient or not available; and, j
A suspected error in any analyses, calculations, or testing that could affect the ability of a system, structure or component to perform its safety or support j
function.
t The aforementioned clarification'of SIR applicability provides additional assurance that nonconforming cond.itions', such as the tornado door issue, will be fully evaluated f
and screened for reportability.
11, Tbc Manager of Engineering has been counseled by Executive Management on the-need to consider the reportability aspects of nonconforming conditions.
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Corrective' Actions That Will Be Taken to Prevent Recurrence The following corrective actions will be taken:
1.
In order to standardize design requirements, North Atlantic is currently implementing a design change for the two doors (EF-400 and P-900) that were identified as not i
being capable of withstanding a differential pressure of at least 1.5 psid. This design change is partially implemented and these doors are currently functional as tornado barriers. This design change will be fully implemented. in the near' future when l
additional door hardware is received. The pending work does not affect functionality of these doors as tornado barriers.
l 2.
Independent of the above events, North Atlantic is developing a new procedure that' j
will enhance the Corrective Action Program by consolidating deficiency reporting j
methods and standardizing the problem evaluation and resolution process. It is anticipated that this procedure will utilize three corrective action vehicles, the existing SIR and OIR, and a new North Atlantic Problem Report (NAPR). The j
NAPR would serve as a centralized corrective action document. It is anticipated that e
North Atlantic will approve and begin implementing this revised corrective action i
procedure by June 30,1993.
The Manager of Engineering has also requested the ESAR process be fac'tored into the overall enhancement of the Corrective Action Program.
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3.
A task force has been convened to review a random sample of engineering activities -
j to identify if any other engineering issues exist that are required to be reported to l
the NRC. This t ask force will be comprised of personnel from both Engineering and i
other independent non-engineering departments.. It is anticipated that this review will
-l be completed by July 15, 1993.
4.
The Engineering Department will evaluate the results of the Nuclear Safety Audit '
Review Committee (NSARC) reviews of safety evaluations to determine if there are 1
any specific trends that may assist in identifying unique areas / activities that would require additional review by the Engineering Department. The first review is-scheduled to be completed by July 15, 1993.
E.
Date When Full Comriliance Will Be Achieved North Atlantic is currently in full compliance with all regulatory requirements cited in this
[
This compliance was achieved when the subject nonconforming condition wcs reported to the NRC, and when it was included in the UFSAR after having performed the requisite safety evaluation.
The corrective actions that have been implemented to-date ensure that North Atlantic's current corrective action program is capable of preventing recurrence.
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